For a list of sanctions placed on Iran, Hezbollah and the Iranian Revolutionary Guard Corps, go here.

Today, President Trump delivered his talk about formally decertifying the JCPOA and naming all of the IRGC a terror organization, finally. This is a significant decision and it puts countries like Iraq, Yemen, Syria and Lebanon on notice to purge all IRGC from their territories.

Earlier this week, the Trump administration was laying the groundwork as it related to Hezbollah by offering a reward for 2 Hezbollah leaders.

None of these actions are without future conflict and militancy by Iran. Just in recent days, the Iranian militia in Iraq it appears has been planting advanced EFP’s, where one did in fact kill an American military soldier that was on a major road in Salahuddin province, north of Baghdad

“It was a classic ambush spot,” White said of the assault site, adding that the penetrator used was steel. Operation Inherent Resolve spokesman Army Col. Ryan Dillon did not cast blame on any particular actor on the battlefield telling the Washington Post, “investigations are continuing into the type and quality of the bomb to better determine where it originated. To say whether or not ISIS did it or not — we have not determined that yet. We are not ruling anything out.”

Chairman of the Joint Chiefs of Staff Marine Gen. Joseph Dunford told Congress in 2015, “I know the total number of soldiers, sailors, airmen and Marines that were killed by Iranian activities, and the number has been recently quoted as about 500,” in a reference to EFP use in Iraq.

“What makes E.F.P.’s so deadly is that they form “slugs” at detonation that maintain their shape over distances of over 100 yards or more, traveling at speeds of nearly a mile per second. This allowed insurgent forces to hide these weapons far from the road, better camouflaging them and making them far more deadly,” The New York Times explained in 2013. More here.

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Related reading: Trump Decertifying and Re-tooling Iran Nuclear Deal

Treasury Designates the IRGC under Terrorism Authority and Targets IRGC and Military Supporters under Counter-Proliferation Authority

10/13/2017

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WASHINGTON – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Iran’s Islamic Revolutionary Guard Corps (IRGC) pursuant to the global terrorism Executive Order (E.O.) 13224 and consistent with the Countering America’s Adversaries Through Sanctions Act.  OFAC designated the IRGC today for its activities in support of the IRGC-Qods Force (IRGC-QF), which was designated pursuant to E.O. 13224 on October 25, 2007, for providing support to a number of terrorist groups, including Hizballah and Hamas, as well as to the Taliban.  The IRGC has provided material support to the IRGC-QF, including by providing training, personnel, and military equipment.

Additionally, today OFAC designated four entities under E.O. 13382, which targets weapons of mass destruction proliferators and their supporters, for their support to the IRGC or Iran’s military.

“The IRGC has played a central role to Iran becoming the world’s foremost state sponsor of terror.  Iran’s pursuit of power comes at the cost of regional stability, and Treasury will continue using its authorities to disrupt the IRGC’s destructive activities,” said Treasury Secretary Steven T. Mnuchin.  “We are designating the IRGC for providing support to the IRGC-QF, the key Iranian entity enabling Syrian President Bashar al-Assad’s relentless campaign of brutal violence against his own people, as well as the lethal activities of Hizballah, Hamas, and other terrorist groups. We urge the private sector to recognize that the IRGC permeates much of the Iranian economy, and those who transact with IRGC-controlled companies do so at great risk.”

IRGC

The IRGC was designated today for the activities it undertakes to assist in, sponsor, or provide financial, material, or technological support for, or financial or other services to or in support of, the IRGC-QF.  The IRGC, which is the parent organization of the IRGC-QF, was previously designated pursuant to E.O. 13382 on October 25, 2007, in connection with its support to Iran’s ballistic missile and nuclear programs, and pursuant to E.O. 13553 on June 9, 2011 and E.O. 13606 on April 23, 2012, in connection with Iran’s human rights abuses.

The IRGC has provided material support to the IRGC-QF, including by providing training, personnel, and military equipment.  The IRGC has trained IRGC-QF personnel in Iran prior to their deployments to Syria, and has deployed at least hundreds of personnel from its conventional ground forces to Syria to support IRGC-QF operations.  IRGC personnel in Syria have provided military assistance to the IRGC-QF, and have been assigned to IRGC-QF units on the battlefield, where they provide critical combat support, including serving as snipers and machine gunners.

Additionally, the IRGC has recruited, trained, and facilitated the travel of Afghan and Pakistani nationals to Syria, where those personnel are assigned to, and fight alongside, the IRGC-QF.  The IRGC also has worked with the IRGC-QF to transfer military equipment to Syria.  The IRGC used both IRGC bases and civilian airports in Iran to transfer military equipment to Iraq and Syria for the IRGC-QF.

Iran Nuclear Agreement Review Act of 2015

(Sec. 2) This bill amends the Atomic Energy Act of 1954 to direct the President, within five days after reaching an agreement with Iran regarding Iran’s nuclear program, to transmit to Congress:

• the text of the agreement and all related materials and annexes;
• a related verification assessment report of the Secretary of State;
• a certification that the agreement includes the appropriate terms, conditions, and duration of the agreement’s requirements concerning Iran’s nuclear activities, and provisions describing any sanctions to be waived, suspended, or otherwise reduced by the United States and any other nation or entity, including the United Nations; and
• a certification that the agreement meets U.S. non-proliferation objectives, does not jeopardize the common defense and security, provides a framework to ensure that Iran’s nuclear activities will not constitute an unreasonable defense and security risk, and ensures that Iran’s permitted nuclear activities will not be used to further any nuclear-related military or nuclear explosive purpose, including any related research.

The Secretary is directed to prepare a report assessing:

• the Secretary’s capacity to verify Iran’s compliance with the agreement,
• the adequacy of the agreement’s safeguards to ensure that Iran’s permitted activities will not be used to further any nuclear-related military or nuclear explosive purpose, including research; and
• the International Atomic Energy Agency’s capacity to implement the required verification regime.

In preparing a report the Secretary shall assume that Iran could:

• use all measures not expressly prohibited by the agreement to conceal activities that violate its obligations under the agreement; and
• alter or deviate from standard practices in order to impede verification efforts.

The foreign relations committees shall hold hearings and briefings to review an agreement during the 30-day period following the President’s transmittal of such agreement.

The congressional review period shall be 60 days for an agreement, including all materials required to be transmitted to Congress, that is transmitted between July 10, 2015, and September 7, 2015.

The President may not waive, suspend, reduce, provide relief from, or otherwise limit the application of statutory sanctions with respect to Iran or refrain from applying sanctions pursuant to an agreement prior to and during the transmission period and during the congressional review period.

The President may not waive, suspend, reduce, provide relief from, or otherwise limit the application of statutory sanctions with respect to Iran or refrain from applying sanctions pursuant to an agreement for:

• 12 days after the date of passage of a congressional joint resolution of disapproval, and
• 10 days after the date of a presidential veto of a congressional joint resolution of disapproval.

Specified deferrals, waivers, or other suspensions of statutory sanctions are excepted from such prohibitions.

It is the sense of Congress that:

• the sanctions regime imposed on Iran by Congress is primarily responsible for bringing Iran to the table to negotiate on its nuclear program;
• these negotiations are a critically important matter of national security and foreign policy for the United States and its closest allies;
• this Act does not require a vote by Congress for the agreement to commence;
• this Act provides for congressional review, including for approval, disapproval, or no action on statutory sanctions relief under an agreement; and
• even though the agreement may commence, because the sanctions regime was imposed by Congress and only Congress can permanently modify or eliminate that regime, it is critically important that Congress have the opportunity to consider and take action affecting the statutory sanctions regime.

An action involving statutory sanctions relief by the United States pursuant to an agreement or the Joint Plan of Action:

• may be taken if, during the review period, Congress enacts a joint resolution stating that Congress favors the agreement;
• may not be taken if, during the review period, Congress enacts a joint resolution stating that Congress does not favor the agreement; or
• may be taken if, following the review period, there is not enacted any such joint resolution.

The President shall keep Congress fully and currently informed of all aspects of Iranian compliance with respect to an agreement.

The President shall:

• within 10 days of receiving information relating to a potentially significant breach or compliance incident by Iran submit it to Congress;
• within 30 days after submitting such information determine whether it constitutes a material breach or compliance incident and report that determination to Congress as well as Iran’s action or failure to act that led to the material breach, actions necessary for Iran to cure the breach, and the status of Iran’s efforts to cure the breach; and
• at least every 180 days thereafter report to Congress on Iran’s nuclear program and compliance with the agreement.

The President shall keep Congress fully informed of any initiative or negotiations with Iran concerning Iran’s nuclear program, including any new or amended agreement.

The President shall, at least every 90 days, determine whether the President is able to certify that:

• Iran is fully implementing the agreement,
• Iran has not committed a material breach of the agreement,
• Iran has not taken any action that could significantly advance its nuclear weapons program, and
• suspension of sanctions against Iran is appropriate and proportionate to measures taken by Iran with respect to terminating its illicit nuclear program and vital to U.S. national security interests.

It is the sense of Congress that:

• U.S. sanctions on Iran for terrorism, human rights abuses, and ballistic missiles will remain in place under an agreement;
• issues not addressed by an agreement on Iran’s nuclear program, including compensation for Americans held in captivity after the seizure of the U.S. Embassy in Tehran, Iran, in 1979, the freedom of Americans held in Iran, the human rights abuses of the government of Iran against its own people, and the continued support of terrorism by the government of Iran, are matters critical to ensure justice and U.S. national security, and should be addressed;
• the President should determine the agreement in no way compromises the U.S. commitment to Israel’s security, nor its support for Israel’s right to exist; and
• in order to implement any long-term agreement reached between the P5+1 countries and Iran, it is critically important that Congress have the opportunity to review any agreement and take action to modify the statutory sanctions regime imposed by Congress.

If the President does not submit such certification or has determined that Iran has materially breached an agreement, Congress may initiate within 60 days expedited consideration of legislation reinstating statutory sanctions against Iran. Sets forth House and Senate provisions regarding such expedited consideration.

Nothing in this Act shall be construed as:

• modifying the President’s authority to negotiate, enter into, or implement executive agreements, other than the restrictions on implementation of the agreements specifically covered by this Act;
• allowing any new waiver, suspension, reduction, or other relief from statutory sanctions with respect to Iran under any provision of law, or allowing the President to refrain from applying any such sanctions pursuant to an agreement during the period for congressional review;
• revoking or terminating any statutory sanctions imposed on Iran; or
• authorizing the use of military force against Iran.